20200115PAC to IIPA WA UE BWP (1-22).pdf

January 14, 2020 Lance Kaufman 4801 E. Yale Avenue
Denver, CO 80219 [e-mail] (C) Nina Suetake Public Counsel Unit
Office of Attorney General 800 Fifth Avenue, Suite 2000 Seattle, WA 98104 [e-mail] (C)
Tyler Pepple Davison Van Cleve, P.C. 1750 SW Harbor Way, Suite 450 Portland, OR 97201 [e-mail] (C)
RE: WA UE-180778 PC-BWP 1st Set Data Request (1-22)
Please find enclosed Pacific Power & Light Company’s 13th Supplemental Response to PC-BWP Data Request 1. Also provided are Attachments to PC-BWP 1d and 1e 13th Supplemental. If you have any questions, please call me at 503-813-5410. Sincerely,

__/s/___ Ariel Son Regulatory Affairs Manager
Enclosures
C.c. Matthew Gerhart/Sierra Club [e-mail] (C) Ana Boyd/Sierra Club [e-mail] (C) David Panco/WUTC [e-mail] (C) Nash Callaghan/WUTC [e-mail] (C)
UE-180778 / Pacific Power & Light Company January 14, 2020
PC-BWP Data Request 1 – 13th Supplemental PC-BWP Data Request 1 Please provide copies of any and all data requests submitted to you by any party
to the following proceedings and your corresponding responses to those data requests. This is an ongoing request: (a) Public Utility Commission of Oregon Docket No. UM 1968;
(b) Washington Utilities and Transportation Commission Filing Docket UE-180778; (c) Idaho Public Utilities Commission Case No. PAC-E-18-08;
(d) Wyoming Public Service Commission Docket No. 20000-539-EA-18; and (e) Utah Public Service Commission Docket No. 18-035-36. 13th Supplemental Response to PC-BWP Data Request 1
PacifiCorp continues to object to this request as overly broad, unduly burdensome, and outside the scope of this proceeding. Without waiving any objections, the company responds as follows:
(a) There has been no additional discovery in Oregon. (b) PC-BWP will be provided copies of discovery on an ongoing basis.
(c) There has been no additional discovery in Idaho.
(d) Please refer to Attachment PC-BWP 1d 13th Supplemental. (e) Please refer to Attachment PC-BWP 1e 13th Supplemental.

The company does not waive any objections raised in the data request responses included in the attachments. Going forward, PC-BWP will be provided supplemental responses to this data
request as requests and responses are received.
PREPARER: Kaley McNay
SPONSOR: Not Applicable
Despite PacifiCorp's diligent efforts, certain information protected from disclosure by the attorney-client privilege or other applicable privileges or law may have been included in its responses to these data requests. PacifiCorp did not intend to waive any applicable privileges or rights by the inadvertent disclosure of protected information, and PacifiCorp reserves its right to request the return or destruction of any privileged or protected materials that may have been inadvertently disclosed. Please inform PacifiCorp immediately if you become aware of any inadvertently disclosed information.